SECUNDA SYNFUELS OPERATIONS: TAR, PHENOSOLVAN & … · 2019. 11. 12. · Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP Environmental

SECUNDA SYNFUELS OPERATIONS: TAR, PHENOSOLVAN & SULPHUR

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.22.3GS1 - THIRD TERTIARY TAR SEPARATORS

16 MAY 2019

CONFIDENTIAL

WSP Environmental (Pty) Ltd.

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT

17.2.22.3GS1 - THIRD TERTIARY TAR SEPARATORS

SECUNDA SYNFUELS OPERATIONS: TAR,

PHENOSOLVAN & SULPHUR

TYPE OF DOCUMENT (VERSION)

CONFIDENTIAL

PROJECT NO.: 41101534

DATE: MAY 2019

WSP

BUILDING C

KNIGHTSBRIDGE, 33 SLOANE STREET

BRYANSTON, 2191

SOUTH AFRICA

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Q U A L I T Y M A N A G E M E N T

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Review –

Compliance Audit

Exemption Ref:

17.2.22.3GS1

Final report –

Compliance Audit

Exemption Ref:

17.2.22.3GS1

Date April 2019 May 2019

Prepared by Ziyaad Kadwa Ziyaad Kadwa

Signature -

Checked by Jenny Cope Jenny Cope

Signature

Authorised by Jenny Cope Jenny Cope

Signature

Project number 41101534 41101534

Report number 017 017

File reference file:///W:\000 NEW Projects\41101534 - Sasol EA and EMP Audits\42 ES\2-REPORTS\

S I G N A T U R E S

PREPARED BY

-

Ziyaad Kadwa

Consultant

REVIEWED BY

Jenny Cope

Associate

This Compliance Audit report (Report) has been prepared by WSP Environmental (Pty) Ltd (WSP) on behalf

and at the request of Sasol Synfuels: Secunda Operations (Client), to provide the Client with an understanding

of their compliance with the conditions included in the Exemption.

Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other

than the Client for the contents of, or any omissions from, this Report.

To prepare this Report, we have reviewed only the documents and information provided to us by the Client or

any third parties directed to provide information and documents to us by the Client. We have not reviewed any

other documents in relation to this Report, except where otherwise indicated in the Report.

P R O D U C T I O N T E A M

CLIENT

SHE: Environmental Compliance

Specialist

Broni van der Meer

Tar, Phenosolvan & Sulphur Production

Senior Manager

July Mavuso

WSP

Associate Jenny Cope

Lead Auditor Anri Scheepers

Lead Auditor Ashlea Strong

Consultant Ziyaad Kadwa

ENVIRONMENTAL EXEMPTION COMPLIANCE AUDIT REPORT Project No. 41101534 SECUNDA SYNFUELS OPERATIONS: TAR, PHENOSOLVAN & SULPHUR

WSP May 2019

TABLE OF CONTENTS

1 INTRODUCTION ........................................ 1

1.1 Terms of Reference ................................................. 1

1.2 Installation of the Third Tertiary Tar Separators

(Authorisation Number: 17.2.22.3GS1) ................. 1

2 AUDIT SCOPE ........................................... 3

3 AUDIT METHODOLOGY ........................... 4

3.1 Audit Checklist ........................................................ 4

3.2 Site Inspection ......................................................... 4

3.3 Documentation Considered ................................... 4

3.4 Audit Compliance Assessment .............................. 5

3.5 Audit Team ............................................................... 5

3.6 Assumptions and Limitations ................................ 6

4 AUDIT FINDINGS ...................................... 7

5 SUMMARY OF THE AUDIT FINDINGS ... 12

5.1 Environmental Exemption .................................... 12


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TABLES

TABLE 1: COMPLIANCE LEVEL DEFINITION AND TARGET COMPLETION DATES .................. 5

TABLE 2: AUDIT FINDINGS – EXEMPTION 7 TABLE 3: SUMMARY OF EXEMPTION

COMPLIANCE AUDIT FINDINGS .................................... 12

FIGURES

FIGURE 1: SSO – THIRD TERTIARY SEPARATORS (SOURCE: GOOGLE EARTH, 2018) ............... 2

FIGURE 2: NUMBER/COUNT CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..... 13

FIGURE 3: OVERALL COUNT FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS ........ 13

FIGURE 4: PERCENTAGE CONTRIBUTION OF FINDINGS MADE TO THE EXEMPTION CONDITIONS PER SECTION ..................................... 14

FIGURE 5: OVERALL PERCENTAGE FINDINGS ON COMPLIANCE TO THE EXEMPTION CONDITIONS 14

APPENDICES

A ENVIRONMENTAL EXEMPTION (17.2.22.3GS1)


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1 INTRODUCTION

1.1 TERMS OF REFERENCE

Sasol South Africa (Pty) Limited operating through its Secunda Synfuels Operations (Sasol) appointed WSP

Environmental (Pty) Ltd (WSP) as an independent environmental consultant, to undertake a compliance audit

and compile an audit report according to the requirements of the National Environmental Management Act (No.

107 of 1998) as amended (NEMA). This report presents the findings of the compliance audit completed for the

Exemption (Reference number: 17.2.22.3GS1 issued on 04 July 2005) for the period December 2014 to

February 2019.

1.2 INSTALLATION OF THE THIRD TERTIARY TAR

SEPARATORS (AUTHORISATION NUMBER:

17.2.22.3GS1)

Sasol received an Exemption for the installation of the third tertiary tar separators at the Gas Liquor Separation

(GLS) plant (Units 13/213). The Exemption was issued by the Mpumalanga Department of Agriculture and

Land Administration, Gert Sibande District Environmental Management with conditions as set out in an

attached Record of Decision (RoD) (in essence an EA).

The activity authorised in terms of the of the Exemption, entailed the installation of a third parallel tertiary

separator at the same capacity of the pre-existing two separators, as well as a distribution pot at the GLS unit.

The distribution pot consists of an overflow weir to split the combined flow in three equal streams, each routed

by gravity to a dedicated tertiary separator. The clean gas from each separator is routed to the clean gas liquor,

from where it is pumped to the phenosolvan gas liquor storage tanks. The oil recovered from all three tertiary

separators is routed to the oil rundown tanks.

The GLS units separate water from hydrocarbons as found in the three gas liquor streams that originate from the

gasification process. This is completed via a series of settling tanks (cooling is completed throughout the process

to bring the various gas liquor streams to appropriate temperatures for atmospheric pressure operations) where

the water is drawn off and sent to Phenosolvan and the hydrocarbons (both oils and tar) are sent to Coal Tar

Filtration (CTF).

Figure 1 provides the location of the separators within the Sasol Secunda Primary area.


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Figure 1: SSO – Third Tertiary Separators (Source: Google Earth, 2018)


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2 AUDIT SCOPE The 7 April 2017 amendment to the Environmental Impact Assessment (EIA) regulations introduced the

requirement for the auditing for all EAs and EMPrs in effect on 8 December 2014 and submission of audit

reports to the Department of Environmental Affairs (DEA) by 7 December 2019 and every five years thereafter.

This audit is designed to meet the requirements of Regulation 34 of the EIA Regulations, 2014.

The audit period runs from December 2014 to February 2019, therefore any construction related conditions that

would have been relevant pre-December 2014 are considered not applicable (outside audit period).

The objective of the audit was to:

— Assess the level of compliance with the conditions of the Exemption;

— Identify and assess any new impacts and risks that result from undertaking the activity;

— Make recommendations in order to achieve compliance in terms of the Exemption;

— Ensure the commitments contained in Condition 7.01 of the Exemption are completed, more specifically:

— “Records relating to the compliance or non-compliance with the conditions of the Authorization must be

kept in good order. Such records must be made available to this Department within seven (07) working

days from the date of a written request for such records by the Department”


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3 AUDIT METHODOLOGY The International Organisation of Standardisation (ISO) 14010, ISO 14011 and ISO 14012 guideline documents

were utilised as a template during the compliance audit process. This methodology ensures that the compliance

audit was conducted in a systematic and independent manner that was documented and objectively evaluated to

determine compliance to the Exemption conditions.

The audit process comprised the following:

— Confirmation of the audit checklist;

— Site inspection (12 March 2019);

— Review of documentation relevant to the conditions of the Exemption (e.g. records,

permits/certificates/maintenance logs/monitoring results/previous reports etc.); and

— Compilation of an audit report.

3.1 AUDIT CHECKLIST

WSP compiled an audit checklist to assist with the Exemption compliance audit (Section 4).

3.2 SITE INSPECTION

Ziyaad Kadwa conducted the site inspection on 12 March 2019. The findings and observations of the site visit

are recorded and summarised in Section 4 with evidence included in Table 2. Key personnel interviewed

included:

— Piet Kleynhans (Area Manager; TPS Production: Carbo Tar).

— Collin Jaynarain (Area Manager; Gas Liquor Separation: Unit 213).

3.3 DOCUMENTATION CONSIDERED

The following documentation was provided and considered:

— SSO DQS ISO 14001 2015;

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27;

— IWWMP (2018-05-15);

— AELs (x6);

— Work Instruction: Minimum Requirements for Environmental Risk Assessments (SGI-SHE-000014);

— Aspects Register_RoD Conditions_13Jul05;

— 3.05_GW_Report _Prj6143_2018-06-19;

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-20;

— Complaints Register (FY 2014-2018);

— 17.2.22.3GS1_2005-07-04 (Department of Agriculture and Land Administration, Gert Sibande District

Environmental Management; Exemption dated 04 July 2005); and,

— Various email correspondence.


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3.4 AUDIT COMPLIANCE ASSESSMENT

WSP utilised a pre-prepared audit checklist to assist with the audit execution (Table 2). The checklist included

the conditions and associated requirements as specified in the Exemption.

Each condition was verified, either by reviewing documentation, interviewing employees and/or visually

inspecting the facility. Each condition was rated in accordance with Table 1 below, and recommendations with

associated target completion dates included.

It should be noted that some of the Exemption conditions were apportioned according to the elements requiring

compliance assessment therein. Although some elements of the condition may have been compliant, if one of

the elements was determined to be non-compliant, the entire condition has been reported as such (and counted

as such during percentage compliance calculation). This apportionment further allowed for the development of

focussed recommendations and timeframes.

Table 1: Compliance Level Definition and Target Completion Dates

COMPLIANCE LEVEL DEFINITION

Compliant (C) Sasol could provide evidence for compliance with the commitment and condition and/or

relevant actions were implemented.

Non-compliant (NC) Specified commitments, conditions and documents were not in place or implemented

according to the requirements of the Exemption. Non-complaint conditions are given target

completion dates, as follows:

— Short term: 0 – 6 months.

— Medium term: 6 – 12 months.

— Long term: 12 – 18 months.

Not applicable (N/A) These are commitments are either not required yet or not applicable to Sasol.

— Conditions marked as “Noted” are considered information points only.

— Where conditions are considered “not auditable” within the scope of this assessment this

is stated and explained within the condition commentary.

Refer to Section 4 for the detailed audit findings (including evidence, recommendations and target completion

dates).

3.5 AUDIT TEAM

The Consultant, Ziyaad Kadwa, was hosted by Broni van der Meer, Piet Kleynhans, and Collin Jaynarain, to

whom we express our gratitude for their time and attention during our visit. A brief summary of the external

auditors’ experience is provided below.

— Auditor: Ziyaad Kadwa

Ziyaad has 8 years’ experience. He completed his National Diploma in Agriculture (Plant and Animal

Production) at Cedara College of Agriculture in 2010. He then completed his Bachelor of Technology at the

Nelson Mandela Metropolitan University in 2012, specialising in Agricultural Management. He completed it

part time whilst working at the KZN Department of Agriculture, Environmental Affairs, and Rural

Development for 3 years. He is currently completing his BSc Honours in Environmental Management part

time at the University of South Africa. Ziyaad has experience working as an Environmental Auditor for a

number of high profile clients in various industries. He has three years of auditing experience, and has

successfully completed general and permit or licence specific audits for the ROSE Foundation, Sappi, RBM,

Impala Platinum and NPC (InterCement). He has also done environmental management programme audits

for BRPM and for various infrastructure projects as part of environmental control officer duties.


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— Project Manager and Quality Assurance: Jenny Cope

Jenny is an environmental due diligence specialist, with over 11 years’ experience in the Environmental

Sector. Jenny’s experience includes managing and completing projects and portfolios internationally;

undertaking both detailed and broad Environmental, Health & Safety compliance and audits of across a

range of sectors. Jenny’s recent experience includes completion and management of several pan-European

and global projects requiring reviews of extensive virtual data rooms, on a very rapid turnaround, and

providing clients with ‘red flag’ reports to give clear commercial advice. Jenny has worked both in

environmental consultancies and with a developer, giving context to understanding the practicalities of

implementing recommendations.

3.6 ASSUMPTIONS AND LIMITATIONS

This Report has been prepared by WSP on behalf and at the request of Sasol, to provide the Client an

understanding of the Relevant Documents.

Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other

than the Client for the contents of, or any omissions from, this Report.

To prepare this Report, we have reviewed only the documents and information provided to us by the Client or

any third parties directed to provide information and documents to us by the Client. We have not reviewed any

other documents in relation to this Report and except where otherwise indicated in the Report.

The findings, recommendations and conclusions given in this report are based on the author’s best scientific and

professional knowledge, as well as available information. This report is based on survey and assessment

techniques which are limited by time and budgetary constraints relevant to the type and level of investigation

undertaken; WSP and its staff reserve the right to modify aspects of the report including the recommendations if

and when new information may become available from on-going research or further work in this field, or

pertaining to this investigation.

Although WSP exercises due care and diligence in rendering services and preparing documents, WSP accepts

no liability, and Sasol, by receiving this document, indemnifies WSP and its directors, managers, agents and

employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or

in connection with the services rendered, directly or indirectly by the use of the information contained in this

document.

This report must not be altered or added to without the prior written consent of the author. This also refers to

electronic copies of this report which are supplied for the purposes of inclusion as part of other reports.

Similarly, any recommendations, statements or conclusions drawn from or based on this report must make

reference to this report. If this report is used as part of a main report, the report in its entirety must be included

as an appendix or separate section to the main report.


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4 AUDIT FINDINGS Table 2: Audit Findings – Exemption

REF: COMMITMENT COMPLIANCE FINDING RECOMMENDATION

1. GENERAL CONDITIONS

1.01 This exemption refers only to the project as specified above

and described in the Record of Decision. Separate

application/s must be lodged for any other development and

/or activity at or near the proposed site, which is covered by

section 21 and 22 of the Act and Government Notice R1182

of 5 September 1997.

C The activity remains as specified and no further alterations or

applications have been made.

None.

1.02 Exemption is only granted in terms of Section 28 (A) of the

Act, and does not exempt the holder from compliance with

any other relevant legislation.

C The Sasol Complex operates with a dedicated environmental and

legal team, and therefore ensures that they comply with applicable

legislation.

In addition, site is operated under ISO14001:2015, which requires

the compilation of a legal register. Furthermore, WSP has been

provided with the 2018 ISO audit for review, which confirms

conformance with requirements to determine compliance

obligations, and how these apply to the organisation.

Evidence:

— SSO DQS ISO 14001 2015; and,

— Audit report_383569_ISO 14001_2015_stage2_2018-07-27.

None.

1.03 No development may take place on the area of concern

without the necessary permits/approvals and/or service

agreements, from other relevant authorities.

N/A This condition is considered outside of the audit period

(construction pre-2014). It is therefore considered not applicable.

No development has occurred onsite subsequent to the initial

construction.

None.


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1.04 Copies of relevant permits, approvals and/or service

agreements must be in possession of this Department before

any construction work commences.



None.

1.05 This Department may change, add to and/or amend any of

the conditions in this exemption if, in the opinion of the

Department, it is environmentally justified.

N/A No changes or amendments have been communicated to Sasol by

the Department since issue of the Exemption.

None.

2. ESTABLISHMENT OF THE DEVELOPMENT

2.01 This exemption is repealed if the proposed project has not

been started within (2) years from the date of this exemption. N/A This condition is considered outside of the audit period


None.

2.02 Fourteen (14) days written notice must be given to this

Department before any construction activities commence. N/A This condition is considered outside of the audit period


None.

3. CONSTRUCTION AND OPERATION

3.01 If any changes need to be made to the site and/or associated

infrastructure, this Department must be informed at least

thirty (30) days in advance, to be able to decide whether the

changes need authorization or not.

N/A The activity remains as specified and no further alterations or

applications have been made.

None.

3.02 Good environmental practice must be carried out as an

integral aspect of the project implementation. N/A This condition is considered outside of the audit period


None.

3.03 All the mitigation measures as proposed in the scoping

report must be adhered to. C The mitigation measures referred to were provided to the auditor

for reference. The construction phase measures are no longer

applicable to the project. Operational mitigation measures are set

out in an aspect register and have been assigned responsible

parties.

OFI:

The operation and

maintenance phase

mitigation measures

(referred to as Category D

in the aspect register) be


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Evidence:

— Aspects Register_RoD Conditions_13Jul05.

audited against at least

once, to confirm

compliance.

4. WASTE

4.01 All waste generated during construction shall be handled and

disposed of in an environmentally acceptable way and as

directed by this Department or any other relevant authority.



None.

5. WATER POLLUTION

5.01 It is the responsibility of the applicant and the relevant

contractor on site to prevent any pollution of surface as well

as groundwater.

C Surface water is managed at the site; the tanks and loading areas

are within hard surfaced and bunded areas that drain to an enclosed

system that pumps the water for reprocessing. No evidence of

significant pollution was observed by the auditor during the site

inspection.

Surface water monitoring is conducted on a weekly basis as well as

real time for the various Receiving Environment Surface

Monitoring (RESMs).

Groundwater monitoring is conducted biannually and quarterly.

The groundwater and surface water monitoring data was reviewed,

and no contamination directly attributable to the facility was noted.

The latest IWWMP as well as surface and groundwater monitoring

results were provided to the auditor as evidence.

Evidence:

— IWWMP SIC 2015 Final_2018-05-15;

— 3.05_GW_Report _Prj6143_2018-06-19; and,

— GWMonitor Report Nov 2017 Final_Prj6129rev-01_2018-11-

20.

None.


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6. RISK ASSESSMENT

6.01 As indicated by relevant authority. C Environmental Risk Assessments are completed every five years

throughout the complex. If a major incident occurs, or a process

change or new installation occurs, the assessment is revised.

The assessments are undertaken by Sasol’s Safety, Health and

Environment (SHE) Risk department, and is undertaken in

accordance with a procedure (SGI-SHE-000014).

Evidence:

— Work Instruction: Minimum Requirements for Environmental

Risk Assessments (SGI-SHE-000014).

None.

7. REPORTING

7.01 Records relating to the compliance or non-compliance with

the conditions of the Authorization must be kept in good

order. Such records must be made available to this

Department within seven (07) working days from the date of

a written request for such records by the Department.

N/A This audit represents the first required audit for this Exemption.

Prior to the introduction of the 7 April 2017 amendment to the

Environmental Impact Assessment (EIA) regulations, no audit

against this EA was required.

None.

7.02 Non-compliance with, or any deviation from the conditions

as set out in the Record of Decision, is regarded as an

offence and, after reasonable provision has been made for

remedial action, will be dealt with in terms of Section 29, 30

and 31A of the Act.

N/A Statement noted by Sasol. None.

7.03 Any complaints regarding the said development must be

brought to the attention of the Department within 24 hours

after receiving the complaint. A complaint's register must be

kept up to date for inspection by members of this

Department.

C All environmental complaints received from interested and

affected parties, both internal and external to the organisation, are

recorded in a complaints register that is maintained by Sasol’s

Environmental Department. Complaints are investigated and

reported in line with the procedure (SGR-SHE-000022) and as per

legal requirements.

None.


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Contact details for the logging of environmental complaints are

communicated to internal and external stakeholders.

The complaints register (FY 2014-2019) was checked and no

complaints related specifically to the third tertiary tar separators

were recorded for this audit period.

Evidence:

— Complaints Register (FY 2014-2018).


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5 SUMMARY OF THE AUDIT FINDINGS

5.1 ENVIRONMENTAL EXEMPTION

The audit findings have been summarised into the following categories: compliance, non-compliance and not

applicable. The overall audit findings concerning compliance to the Exemption conditions are as listed in Table

3 below.

Table 3: Summary of Exemption Compliance Audit Findings

SECTION OF THE EXEMPTION NO. COMMITMENTS C NC N/A

GENERAL CONDITIONS 5 2 0 3

ESTABLISHMENT OF THE DEVELOPMENT 2 0 0 2

CONSTRUCTION AND OPERATION 3 1 0 2

WASTE 1 0 0 1

WATER POLLUTION 1 1 0 0

RISK ASSESSMENT 1 1 0 0

REPORTING 3 1 0 2

Total Count 16 6 0 10

Total Percentage - 38% 0% 63%

Percentage Compliance with Applicable Conditions 100%


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Figure 2 illustrates the number/count contribution of the findings of the EA per section while Figure 3 presents

the total proportion of compliance for the facility.

Figure 2: Number/Count contribution of findings made to the Exemption conditions per Section

Figure 3: Overall count findings on compliance to the Exemption conditions

0

1

2

3

4

5

6Sectional Count Contribution

C

NC

N/A

6

0

10

Total Compliance

C

NC

N/A


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Figure 4 illustrates the percentage contribution of the findings of the EA conditions. Figure 5 presents the total

percentage compliance for the facility.

Figure 4: Percentage contribution of findings made to the Exemption conditions per Section

Figure 5: Overall percentage findings on compliance to the Exemption conditions

0102030405060708090

100Sectional Percentage Contribution

C

NC

N/A

38%

0%

63%

Total Percentage Compliance

C

NC

N/A

APPENDIX

A ENVIRONMENTAL EXEMPTION

(17.2.22.3GS1)